JUDGMENT :

1. Leave granted. These appeals arise out of the common judgment and order passed by the High Court of Madhya Pradesh at Indore in Income Tax Appeal No. 112 of 2008 and other appeals dated 22.6.2009. By the impugned judgment and order, the High Court has concluded, firstly, that since the Income Tax Appellate Tribunal (for short the Tribunal) has recorded a finding of fact that the Respondent herein is a public religious trust, in exercise of its powers under Section 260A of the Income Tax Act, 1961 (for short the Act) it would not be interfering with such a finding of fact and secondly, that the Respondent being a public religious trust, the provisions of Section 13(1)(b) would not be applicable to it and therefore, dismissed the appeal filed by the Revenue confirming the orders passed by the Tribunal, dated 28.3.2008.

2. Propter commoditatem, we would refer to the conspectus of facts in the lead case for the disposal of the instant batch of appeals. The Respondent is a registered Public Trust under the M.P. Public Trusts Act, 1951. The Respondent had filed an application for registration before the Commissioner of Income Tax (for short the Commissioner) as envisaged und